FEDERAL ELECTION COMMISSION

Washington, D.C. 20463

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of )

) MUR 7605

Chad E. Price )

STATEMENT OF REASONS OF CHAIR SHANA M. BROUSSARD AND 

COMMISSIONERS ELLEN L. WEINTRAUB AND STEVEN T. WALTHER

The Complaint in this matter alleged that Chad E. Price (“Chad”), having made the 

maximum contribution to Judson Hill for Congress (“Hill Committee”),1then made a $2,700 

contribution to the Hill Committee in the name of his mentally disabled adult sister, Jessica Price

(“Jessica”), over whom he has legal guardianship.2 The Complaint alleged, and Chad did not 

dispute, that Jessica was born with a rare developmental disability that limits her mental age to 

that of a 3-or 4-year-old.3 Likewise, it is not disputed that Jessica is dependent on others, cannot 

read or write, and is not able to make decisions about matters such as making political 

contributions.4

The Office of General Counsel (“OGC”) concluded that Jessica did not make a knowing 

contribution to Hill’s congressional campaign and that the contribution should be viewed as 

Chad’s contribution.5 And because Chad had already given the maximum contribution to the 

Hill Committee, OGC further concluded that Chad made an excessive contribution in the name 

of another.6 OGC, nevertheless, recommended that the Commission exercise its prosecutorial 

discretion and dismiss the allegation.7 In recommending dismissal, OGC considered, among 

other things, Chad’s argument that he was advised by various campaigns, including the Hill 

Committee, that the contribution was legal; that this is a novel issue in which he lacked fair 

notice that his actions were unlawful; and that this was a single violation involving a small 

amount of money.8

Although we agreed with OGC that Chad violated 52 U.S.C. §§ 30116(a) and 30122 by 

making an excessive contribution in the name of another, we could not support the 

1

Judson Hill was an unsuccessful 2017 special election candidate for the 6th Congressional District of 

Georgia, and his principal campaign committee was Judson Hill for Congress. Statement of Organization, Judson 

Hill for Congress (Jan. 5, 2017). 

2 Compl. at 2, MUR 7605 (Chad E. Price) (May 6, 2018).

3

Id.; Suppl. Resp. at 2, MUR 7605 (Chad E. Price) (Sept. 14, 2020).

4 See Complaint at 2.

5 First General Counsel’s Rpt at 8-9, MUR 7605 (Chad E. Price). 

6

Id. at 9.

7

Id. at 10-11.

8

Id.

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Statement of Reasons

Page 2 of 3

recommendation to dismiss this matter as a matter of prosecutorial discretion. Federal law 

clearly states that “[n]o person shall make a contribution in the name of another.”9It is 

undisputed that Jessica lacked the requisite decisional capacity to make the federal contribution 

at issue.

10

 While the monetary amount of the excessive and prohibited contribution is relatively 

small, there are some matters that are serious enough to warrant enforcement even if the amount 

in violation is modest. Conduit contributions, like the one at issue here, are significant violations 

of federal campaign finance law.

11

 It is particularly grievous to exploit a position of trust to 

make political contributions in someone else’s name.12 In addition to gravity of the violation,

there are questions regarding Chad’s credibility and whether he made the contribution in 

Jessica’s name in order to conceal that he was the source of the funds.

13

Under these circumstances, the Commission should have pursued enforcement of this 

matter. Doing so would have demonstrated the Commission’s commitment to ensuring that 

individuals who lack the mental capacity to make political contributions are not used as conduits 

for the contributions of others, including those of their guardians. Accordingly, we voted to find 

reason to believe that Chad E. Price violated 52 U.S.C. §§ 30116(a) and 30122 and to authorize 

OGC to enter into pre-probable cause conciliation with him to resolve these violations.14

9 52 U.S.C. § 30122. 

10 Consequently, questions about the scope of the guardianship under state law, such as whether he was 

generally permitted to make payments on Jessica’s behalf as her guardian, are inapposite. 

11 While this action only involves the single contribution to the Hill Committee, the record shows that Chad 

also made other contributions in his sister’s name in connection with state races: (1) $5,200 to Nelson Dollar (NC 

House of Representatives); (2) $1,000 to Stephen Baldwin (WV State Senate); and (3) $6,600 to Geoffrey Duncan 

(GA Lieutenant Governor). See Complaint, Attachs.

12 Chad argues that blocking him from contributing in Jessica’s name “would fundamentally disregard Jessica 

Price’s First Amendment right to free speech.” Suppl. Resp. at 5. He has it entirely backwards. Allowing him to 

contribute in her name would allow him to appropriate her First Amendment rights for his own purposes. Being her 

guardian does not entitle him to contribute in Jessica’s name anymore than it entitles him to vote in her name. The 

fact that Jessica is not able to knowingly exercise her political rights does not mean that Chad gets to claim her 

rights for himself.

13 For instance, in connection with the contribution, Chad originally informed the Hill Committee that Jessica 

was an employee of his company, Mako Medical. In his Response, Chad acknowledged that this was inaccurate and 

should be corrected. Resp. at 3, MUR 7605 (June 7, 20019). In addition, Chad’s original Response stated that he 

relied on advice provided by a state candidate and the West Virginia Secretary of State when making the federal 

contribution on behalf of Jessica. Id. at 1, Attach. But in response to the supplemental Complaint, he asserted that, 

prior to making the contribution in Jessica’s name, he contacted multiple recipient state and federal campaigns, 

including the Hill Committee, to ensure that the contributions were “compliant with the provisions of the Act.” 

Suppl. Resp. at 3. According to Chad, he was assured by an unnamed individual from the Hill Committee that his 

contribution on behalf of Jessica as her court-appointed guardian was legally permissible under state and federal 

law. Id. We note that Chad did not have counsel when he filed the original Response, unlike when he filed the 

supplemental Response. For its part, the Hill Committee, in its Response to the Complaint, maintains that it had no 

knowledge of the circumstances under which the contribution was made by Chad, which appears at odds with 

Chad’s assertion. See Hill Committee Resp. at 1-2 (July 11, 2019).

14 Certification ¶ 2, MUR 7605 (Chad E. Price) (Sept. 14, 2021). In addition, the three of us voted to support 

OGC’s recommendation to dismiss the allegations that the Hill Committee accepted an excessive contribution in the 

name of another in violation of 52 U.S.C. §§ 30116(f) and 30122 with a caution to the Hill Committee. Id. ¶ 1.

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Statement of Reasons

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___________________ ____________________________

Date Shana M. Broussard 

Chair

____________________ ____________________________

Date Ellen L. Weintraub

Commissioner

____________________ ____________________________

Date Steven T. Walther

Commissioner

10/27/2021

10/27/2021

10/27/2021

MUR760500086